UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - X UNITED STATES OF AMERICA - v. - SUPERSEDING INDICTMENT NICOLAS MADURO MOROS, S2 11 Cr. 205 (AKH) DIOSDADO CABELLO RONDON, HUGO ARMANDO CARVAJAL BARRIOS, a/k/a "El Pollo," CLIVER ANTONIO ALCALA CORDONES, LUCIANO MARIN ARANGO, a/k/a "Ivan Marquez," and SEUXIS PAUCIS HERNANDEZ SOLARTE, a/k/a "Jesfis Santrich," Defendants. - - - - - - - - - - - - - - - - - - - - X COUNT ONE (Narco-Terrorism Conspiracy) The Grand Jury charges: Overview 1. From at least in or about 1999, up to and including in or about 2020, NICOLAS MADURO MOROS, DIOSDADO CABELLO RONDON, HUGO ARMANDO CARVAJAL BARRIOS, a/k/a "El Pollo," CLIVER ANTONIO ALCALA CORDONES, LUCIANO MARIN ARANGO, a/k/a "Ivan Marquez," and SEUXIS PAUCIS HERNANDEZ SOLARTE, a/k/a "Jesfis Santrich," the defendants, participated in a corrupt and violent narco-terrorism conspiracy between the Venezuelan Cartel de Los Soles and the Fue.rzas Armadas Revolucionarias de Colombia ("FARC").
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
- - - - - X
UNITED STATES OF AMERICA
- v. - SUPERSEDING INDICTMENT
NICOLAS MADURO MOROS, S2 11 Cr. 205 (AKH) DIOSDADO CABELLO RONDON, HUGO ARMANDO CARVAJAL BARRIOS,
a/k/a "El Pollo," CLIVER ANTONIO ALCALA CORDONES, LUCIANO MARIN ARANGO,
a/k/a "Ivan Marquez," and SEUXIS PAUCIS HERNANDEZ SOLARTE,
a/k/a "Jesfis Santrich,"
Defendants.
- - - - - - - - - - - - - - - - - - - - X
COUNT ONE (Narco-Terrorism Conspiracy)
The Grand Jury charges:
Overview
1. From at least in or about 1999, up to and including
in or about 2020, NICOLAS MADURO MOROS, DIOSDADO CABELLO RONDON,
HUGO ARMANDO CARVAJAL BARRIOS, a/k/a "El Pollo," CLIVER ANTONIO
ALCALA CORDONES, LUCIANO MARIN ARANGO, a/k/a "Ivan Marquez," and
SEUXIS PAUCIS HERNANDEZ SOLARTE, a/k/a "Jesfis Santrich," the
defendants, participated in a corrupt and violent narco-terrorism
conspiracy between the Venezuelan Cartel de Los Soles and the
Fue.rzas Armadas Revolucionarias de Colombia ("FARC").
2. From at least in or about 1999, up to and including
in or about 2020, the FARC was a terrorist organization led at
times by LUCIANO MARIN ARANGO, a/k/a "Ivan Marquez," and SEUXIS
PAUCIS HERNANDEZ SOLARTE, a/k/a "Jesus Santrich," the defendants,
among others -- that became one of the largest producers of cocaine
in the world and perpetrated acts of violence against United States
nationals and property.
3. From at least in or about 1999, up to and including
in or about 2020, the Cartel de Los Soles, or "Cartel of the Suns,"
was a Venezuelan drug-trafficking organization comprised of high
ranking Venezuelan officials who abused the Venezuelan people and
corrupted the legitimate institutions of Venezuela -- including
parts of the military, intelligence apparatus, legislature, and
the judiciary -- to facilitate the importation of tons of cocaine
into the United States. The name of the Cartel de Los Soles is a
reference to the sun insignias affixed to the uniforms of high
ranking Venezuelan military officials who are members of the
Cartel.
4. NICOLAS MADURO MOROS, the defendant, helped manage
and, ultimately, lead the Cartel de Los Soles as he gained power
in Venezuela. Under the leadership of MADURO MOROS and others,
the Cartel de Los Soles sought not only to enrich its members and
enhance their power, but also to "flood" the United States with
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cocaine and inflict the drug's harmful and addictive effects on
users in this country. Thus, whereas most drug-trafficking
organizations in South and Central America have sought to recede
from their roles in importing narcotics into the United States in
an effort to avoid U.S. prosecution, the Cartel de Los Soles, under
the leadership of MADURO MOROS and others, prioritized using
cocaine as a weapon against America and imp_orting as much cocaine
as possible into the United States.
5. While pursuing these and other objectives, NICOLAS
MADURO MOROS, the defendant, negotiated multi-ton shipments of
FARC-produced cocaine; directed that the Cartel de Los Soles
provide military-grade weapons to the FARC; coordinated foreign
affairs with Honduras and other countries to facilitate large
scale drug trafficking; and solicited assistance from FARC
leadership in training an unsanctioned militia group that
functioned, in essence, as an armed forces unit for the Cartel de
Los Soles.
The Cartel de Los Soles and the Venezuelan Defendants
6. At various times between 1999 and 2020, NICOLAS
MADURO MOROS, DIOSDADO CABELLO RONDON, HUGO ARMANDO CARVAJAL
BARRIOS, a/k/a "El Pollo,,, and CLIVER ANTONIO ALCALA CORDONES, the
defendants, acted as leaders and managers of the Cartel de Los
Soles and the narco-terrorism conspiracy with the FARC.
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7. NICOLAS MADURO MOROS, the defendant, is a
Venezuelan citizen, was previously the president of Venezuela, and
is now the de facto ruler of the country. MADURO MOROS also
previously held a seat in the Venezuelan National Assembly between
in or about 2000 and in or about 2006, acted as the Venezuelan
foreign minister between in or about 2006 and in or about 2013,
and acted as the vice president of Venezuela in or about 2013.
MADURO MOROS succeeded to the Venezuelan presidency after Hugo
Chavez died in or about 2013 and, during his presidency, continued
to participate in cocaine trafficking with the Cartel de Los Soles
and the FARC. In or about 2018, MADURO MOROS declared victory in
a presidential election in Venezuela. In or about 2019, the
National Assembly of Venezuela invoked the Venezuelan constitution
and declared that MADURO MOROS had usurped power and was not the
president of Venezuela. Since in or about 2019, more than 50
countries, including the United States, have refused to recognize
MADURO MOROS as Venezuela's head of state and instead recognized
Juan Guaid6 as the interim president of Venezuela. In or about
January 2020, the United States Department of State certified the
authority of Guaid6, as the interim president of Venezuela, to
receive and control property in accounts at the United States
Federal Reserve maintained by the Venezuelan government and the
Central Bank of Venezuela.
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8. DIOSDADO CABELLO RONDON, the defendant, is a
Venezuelan citizen, president of Venezuela's National Constituent
Assembly, and a member of the Venezuelan armed forces. CABELLO
RONDON previously acted as chief of staff to Chavez in or about
2001, vice president of Venezuela in or about 2002, governor of
Venezuela's Miranda State between in or about 2004 and in or about
2008, and president of Venezuela's National Assembly between in or
about 2012 and in or about 2016.
9. HUGO ARMANDO CARVAJAL BARRIOS, a/k/a "El Pollo,"
the defendant, is a Venezuelan citizen and was the director of
Venezuela's military intelligence agency, which was known as the
Direcci6n de Inteligencia Mili tar ("DIM"), between in or about
2004 and in or about 2011. In or about 2013, NICOLAS MADURO MOROS,
the defendant, made CARVAJAL BARRIOS the director of the DIM for
a second time. Between in or about January 2014 and in or about
June 2014, CARVAJAL BARRIOS held the title of Venezuela's consul
general to Aruba. In or about January 2016, despite being a
fugitive on drug-trafficking charges that have been pending in the
Southern District of New York since at least in or about 2011,
CARVAJAL BARRIOS was elected to the Venezuelan National Assembly.
As of the filing of this Superseding Indictment, CARVAJAL BARRIOS
remains a fugitive on pending charges in underlying indictments in
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the Southern District of New York and subject to a lawful order of
extradition issued by Spain in or about 2019.
10. CLIVER ANTONIO ALCALA CORDONES, the defendant, is
a Venezuelan citizen and a former general in the Venezuelan
military.
The FARC and the FARC Defendants
11. Between at least in or about 1999, up to and
including in or about 2020, the FARC became one of the largest
producers of cocaine in the world. The FARC has also directed
violent acts against United States persons and property in foreign
jurisdictions, including, but not limited to, Colombia. For
example, the FARC leadership ordered FARC members to kidnap and
murder United States citizens and to attack United States interests
in order to dissuade the United States from continuing its efforts
to fumigate FARC coca fields and disrupt the FARC's manufacturing
and distribution of cocaine and cocaine paste. Consistent with
these activities, in or about 1997, the United States Department
of State designated the FARC as a Foreign Terrorist Organization.
The FARC remains so designated as of the filing of this Superseding
Indictment.
12. LUCIANO MARIN ARANGO, a/k/a "Ivan Marquez," the
defendant, is a Colombian citizen who joined the FARC in or about
1985. In or about 2006, the United States Attorney's Office for
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the Southern District of New York filed a drug-trafficking charge
against 50 leaders of the FARC, including MARIN ARANGO. As of the
filing of this Superseding Indictment, MARIN ARANGO is a fugitive
on that charge and a member of the FARC's Secretariat, which is